1.1 Purpose of this Report

1.1.1 This Report is prepared pursuant to the Order of Master Trench dated 15 December 1998 directing that each party may adduce expert evidence from historians and political scientists to address relevant issues in the proceedings. It has been written to assist the Court by providing an expert opinion on allegations made in Professor Deborah Lipstadt's book Denying the Holocaust: The Growing Assault on Truth and Memory, published in 1994 by Penguin Books, about Mr. David Irving.

1.1.2 The book makes a variety of claims about Irving and his work, to which Irving has objected in his libel writ; only those which fall within the scope of my expertise as a professional historian will be considered. These claims can be summarised under four headings. They are as follows (references are to the page of the book on which they occur):

1.1.3Irving is 'a discredited figure' as a historian (p. 180)

Irving has become a Holocaust denier (p. 111). He had 'long equated the actions of Hitler and Allied leaders, an equivalence that was made easier by his claims that the Final Solution took place without Hitler's knowledge' (p. 162). In 1988, Irving, 'who had long hovered at the edge of Holocaust denial' (p. 162), was converted to the idea that the gas chambers were a myth (p. 179). 'Irving is one of the most dangerous spokespersons for Holocaust denial' (p. 181). He has connections with Holocaust deniers (p. 181).

Irving skews documents and misrepresents data in order to exonerate Hitler. He is 'an ardent admirer of the Nazi leader' (p. 161).

Holocaust deniers 'misstate, misquote, falsify statistics, and falsely attribute conclusions to reliable sources. They rely on books that directly contradict their arguments, quoting in a manner that completely distorts the authors' objectives' (p. 111). Since this statement comes immediately after the allegation that Irving has become a Holocaust denier, the implication that he does all these things too is unmistakable. Indeed, Lipstadt also claims that scholars 'have accused him of distorting evidence and manipulating documents to serve his own purposes' and of 'skewing documents and misrepresenting data in order to reach historically untenable conclusions' (p. 161). 'Familiar with historical evidence, he bends it until it conforms with his ideological leanings and political agenda...he is most facile at taking accurate information and shaping it to confirm his conclusions' (p. 181).

The sources and methods used in this report to assess these claims will be outlined later in this Introduction.